# DSA Transparency — legal context bundle > Curated from overview.legal on 2026-08-22. Canonical page: https://overview.legal/topics/dsa-transparency-reporting-obligations > Sources are cited per item. Verify against the official texts before relying on them. This new topic is needed because the content specifically addresses transparency reporting obligations for intermediary service providers under the DSA, which is a distinct and important compliance requirement that deserves dedicated coverage separate from general transparency obligations or AI-focused transparency requirements. ## Overview ## Legal Framework Transparency reporting under the Digital Services Act is governed primarily by Article 15 and Article 42. Article 15 imposes annual transparency reporting obligations on all providers of intermediary services, including hosting services and online platforms. These reports must cover several mandated categories: the number of orders submitted by Member State authorities to act against illegal content, the number of notices submitted through the notice-and-action mechanisms, the outcomes of those notices, and information about the provider's content moderation practices, including the use of automated tools. Article 42 extends and deepens these obligations specifically for very large online platforms (VLOPs) and very large online search engines (VLOSEs). These entities must publish transparency reports at least every six months and include additional metrics such as the number of active recipients of the service, the number of staff dedicated to content moderation, and detailed breakdowns of automated versus human-driven moderation decisions. The rationale is proportionate: larger platforms with systemic impact face heightened disclosure duties to enable meaningful regulatory oversight and public accountability. The doctrinal principle of proportionality is central here — transparency obligations scale with the risk profile and societal footprint of the service provider, reflecting a tiered regulatory architecture rather than a one-size-fits-all approach. ## Key Developments The European Commission has actively enforced DSA transparency obligations since the Act's full applicability in February 2024. The Commission opened formal proceedings against several VLOPs, including X (formerly Twitter), for suspected failures in transparency reporting, particularly regarding the completeness and accuracy of content moderation disclosures. The Commission's preliminary view indicated that X's advertising repository and transparency reports did not satisfy Article 42 requirements. The Digital Services Coordinators at the national level have also begun scrutinizing smaller platforms' compliance with Article 15. Early enforcement signals indicate that regulators expect transparency reports to be machine-readable, easily accessible on the provider's website, and structured to allow meaningful comparison across reporting periods. Reports that are buried in obscure website sections or lack methodological explanation have drawn regulatory criticism. ## Practical Guidance - **Publish annually at minimum, or semi-annually if designated as a VLOP/VLOSE.** The reporting cadence is determined by your platform's designation status under Article 33. Track designation decisions closely, as they trigger the heightened Article 42 regime. - **Structure reports around the specific categories enumerated in Article 15(1).** These include authority-issued orders, user notices, content moderation outcomes, and automated tooling. Omitting any category renders the report non-compliant, regardless of overall quality. - **Ensure methodological transparency.** Reports must explain how metrics are calculated, what definitions are used for "illegal content," and how automated versus human moderation decisions are distinguished. Vague or inconsistent methodology invites enforcement risk. - **Make reports easily discoverable and machine-readable.** Place them in a dedicated, prominently linked section of your website. Regulators have signaled that accessibility is a compliance threshold, not a best practice. - **Align transparency reporting with internal audit cycles.** Content moderation data must be collected systematically throughout the reporting period. Retroactive data reconstruction is both unreliable and likely to produce the kinds of inconsistencies that trigger regulatory scrutiny. ## Legislation (full text of key provisions) ### Transparency reporting obligations for providers of online platforms *Source: DSA, dsa-art-24-en, 2022-10-19 — https://overview.legal/posts/94410* ### Transparency reporting obligations for providers of intermediary services *Source: DSA, dsa-art-15-en, 2022-10-19 — https://overview.legal/posts/94226* ### Transparency reporting obligations *Source: DSA, dsa-art-42-en, 2022-10-19 — https://overview.legal/posts/94760* ### Recital 49 — intermediary services annual transparency reporting *Source: DSA, dsa-rec-49-en, 2022-10-19 — https://overview.legal/posts/95495* To ensure an adequate level of transparency and accountability, providers of intermediary services should make publicly available an annual report in a machine-readable format, in accordance with the harmonised requirements contained in this Regulation, on the content moderation in which they engage, including the measures taken as a result of the application and enforcement of their terms and conditions. However, in order to avoid disproportionate burdens, those transparency reporting obligations should not apply to providers that are micro or small enterprises as defined in Commission Recommendation 2003/361/EC (25) and which are not very large online platforms within the meaning of this Regulation. ### Recital 65 — online platforms transparency reporting obligations *Source: DSA, dsa-rec-65-en, 2022-10-19 — https://overview.legal/posts/95527* In view of the particular responsibilities and obligations of providers of online platforms, they should be made subject to transparency reporting obligations, which apply in addition to the transparency reporting obligations applicable to all providers of intermediary services under this Regulation. For the purposes of determining whether online platforms and online search engines may be very large online platforms or very large online search engines, respectively, that are subject to certain additional obligations under this Regulation, the transparency reporting obligations for online platforms and online search engines should include certain obligations relating to the publication and communication of information on the average monthly active recipients of the service in the Union. ## Related topics - **Transparency** — https://overview.legal/topics/transparantie Openness about data processing activities - **Transparency Reporting Obligations Overview** — https://overview.legal/topics/transparency-reporting-obligations-overview While individual aspects of transparency reporting are covered by existing topics, there is no comprehensive overview topic that addresses transparency reportin - **VLOP/VLSE Framework** — https://overview.legal/topics/vlop-vlse-regulatory-framework-overview The content title specifically focuses on 'Very large online platforms and very large online search engines' as a distinct regulatory category under the DSA. A - **Supervision** — https://overview.legal/topics/toezicht Oversight and enforcement by supervisory authorities - **DSA Scope and Digital Services Coverage** — https://overview.legal/topics/dsa-scope-digital-services The content is from the DSA (Digital Services Act), not the AI Act. A dedicated topic for DSA scope is needed to distinguish it from AI Act scope provisions and - **DSA Terms and Conditions Requirements** — https://overview.legal/topics/dsa-terms-conditions-requirements This new topic is needed to specifically address the requirements for terms and conditions documents under the DSA, including transparency, accessibility, and m --- Generated by overview.legal · https://overview.legal/topics/dsa-transparency-reporting-obligations · 2026-08-22